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8/30/2017

firstREV Basics (c)HEALTHCAREfirst 05/2017 1

Copyright © 2017 HEALTHCAREfirst. All rights reserved.

FY2018 Hospice Final Rule

Presented by:Deanna Loftus, HEALTHCAREfirst Director of Regulatory ComplianceLiz Silva, HEALTHCAREfirst Director of Hospice Support


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About HEALTHCAREfirst

• Industry leader in Web‐based EHR software, coding & billing services, CAHPS survey administration, and advanced analytics for home health and hospice:

– Founded in 1992

– Headquartered in Springfield, MO with additional office in Louisville, KY

– One of the fastest growing providers of our kind

– More than 4,000 home health and hospice agencies nationwide

• We enable our customers to:– Make timely and accurate decisions for excellent patient care

– Adapt quickly to changing requirements and needs

– Automate agency functions quickly and with high value.


EHR Software and Beyond

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• Strengthen Profitability

• Ensure Compliance

• Improve Quality

Hospice Solution Suite


Agenda

• FY2018 Final Hospice Rule

– New payment rates

– Hospice cap

– Extraordinary Circumstances Exemption and Extensions

– HQRP

– Potential Future rulemaking

• Sources of Clinical information for CTI

• HEART

• Future HQRP Measures

• Hospice Compare

• Important reminders/upcoming billing changes and/or mandates

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FY 2018 Hospice

Final Rule

https://www.gpo.gov/fdsys/pkg/FR‐2017‐08‐04/pdf/2017‐16294.pdf


FY2018 Final RHC Payment Rates

Code Description FY 2017 Pmt. Rates

SBNF Wage IndexStand. Factor

FY 2018 Hosp. Pmt. Update

FY 2018 Final Pmt. Rates

651 Routine Days 1-60

$190.55 X 1.0018 X 1.0000 X 1.01 $192.78

651 Routine Days 61+

$149.82 X 1.0005 X 1.0001 X 1.01 $151.41

*Effective on 10/1/2017

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FY2018 Final Payment Rates (GHC, IRC, GIP)

Code Description FY 2017 Pmt. Rates

Wage IndexStand. Factor

FY 2018 Final Hosp. Pmt. Update

FY 2018 Final Pmt. Rates

652 Continuous Home Care

Full Rate=24 hours of Care

$=40.68/hourly rate

$964.63 X 1.022 X1.01 $976.42

655 Inpatient Respite Care $170.97 X 1.0006 X1.01 $172.78

656 General Inpatient Care $734.94 X 1.0017 X1.01 $743.55

*Effective on 10/1/2017


Hospice Aggregate Cap

• For accounting years that end after September 30, 2016 and before October 1, 2025, the hospice cap is updated by the hospice update percentage rather than using the consumer price index for urban consumers (CPI-U)

• Hospice cap for the 2018 cap year will be $28,689.04

§ 418.309 Hospice cap amount

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Extraordinary CircumstancesExemption and Extension

• Deadline extended for submitting an exemption or extension request from 30 calendar days to 90 calendar days from the qualifying event that is preventing a hospice from submitting their quality data for the HQRP.

• Policy extended beyond the submission of the HIS date to submission of the CAHPS® Hospice Survey data as multiple data submission processes could be impacted by the same qualifying event.


Extraordinary Circumstances Exemption and Extension

• If a hospice is granted an exemption or extension, timeframes for which an exemption or extension is granted will be applied to the new timeliness requirement so such hospices are not penalized.

– If a hospice is granted an exemption, CMS will not require that the hospice submit HIS and/or CAHPS® Hospice Survey data for a given period of time.

– If a hospice is granted an extension, the hospice will still remain responsible for submitting data collected during the timeframe in question, although CMS will specify a revised deadline by which the hospice must submit the quality data.

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HQRP

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• No new HIS‐based measures for FY2018.

• CMS continues to consider specific measure concepts for potential future proposals. (Including measures that promote care that is person‐centered, high quality, and safe.)


Measure Concepts for Future Years

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• CMS identified two priority areas that will be addressed by claims based measure development:– Potentially avoidable hospice care transitions: encourage hospice

providers to assess and manage patients’ risk of care transitions

– Access to levels of hospice care: assess the rates at which hospices provide different levels of hospice care

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Potential Inclusion of Social Risk Factorsin HQRP

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• Proposed rule: CMS asked for feedback on accounting for social risk factors in measures in the HQRP, and, if so, what method or combination of methods would be most appropriate for accounting for social risk factors.

• Final Rule: CMS has concerns on holding providers to different standards for the outcomes of their patients with social risk factors because CMS does not want to mask potential disparities. Will continue to research and explore options.


Previously Finalized Quality Measures Affecting FY2019 Payment Determination and Subsequent Years

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Hospice Compare Rollout Timeline

• NOW LIVE!– 7 HIS quality measures– Rolling 12‐month timeframe– Minimum of 20 patient stays

• Winter 2018– 8 Hospice CAHPS measures– Rolling 8‐quarter timeframe– Minimum of 30 completed surveys

• Future– Star Ratings– Additional quality measures


8 Hospice CAHPS Quality Measures That Will be Included in Hospice Compare (Winter 2018)

• 2 Global Measures– Rating of patient care (#39)

– Would recommend this hospice (#40)

• 6 Composite Measures– Hospice Team Communications (#6, 8, 9, 10, 14, & 36)

– Getting Timely Care (#5 & 7)

– Treating Family Member with Respect (#11 & 12)

– Getting Emotional & Religious Support (#36, 37, & 38)

– Getting Help for Symptoms (#16, 22, 25, & 27)

– Getting Hospice Care Trainings (#18, 19, 20, 23, & 29)

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Potential Future Rulemaking: Sources of Clinical Information for CTI

• CMS believes the source of the clinical information that supports a patient’s six month life expectancy is not clearly identified, which has raised questions on what clinical information hospice medical directors rely on to support the certification of terminal illness.

• Hospice Medical Directors are currently required to consider at least the following for the certification of terminal illness:

– Diagnosis of the terminal condition of the patient

– Other health conditions, whether related or unrelated to the terminal condition

– Current clinically relevant information supporting all diagnoses

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• Proposed Rule: CMS solicited comments in the proposed rule for possible future rulemaking, on amending regulation §418.25 to specify the referring physician’s and/or the acute/post‐acute care facility’s medical record would serve as the basis for initial hospice eligibility determinations

• Final rule: Acknowledged current regulations already require clinical info from a variety of sources to accompany the hospice CTI and they will work with the MACs to confirm if they are requesting comprehensive clinical info during Medical review

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Potential Future Rulemaking: Sources of Clinical Information for CTI

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New Data Collection and Submission Mechanisms Under Consideration for Future Rulemaking

• CMS will continue to seek stakeholder input on the Hospice Evaluation & Assessment Reporting Tool (HEART)

• Would be a hospice patient assessment tool that would serve two primary objectives as part of the Affordable Care Act legislation: – (1) To provide the quality data necessary for HQRP requirements and

the current function of the HIS and

– (2) To provide additional clinical data that could inform future payment refinements.

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• The new data collection effort:

– Would replace the current HIS

– Would not replace other HQRP data collection efforts (CAHPS® Hospice Survey), nor would it replace regular submission of claims data

• HEART will most likely be the subject of future rulemaking

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New Data Collection and Submission Mechanisms Under Consideration for Future Rulemaking

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Hospice Compare and Public Reporting


Hospice Compare

• www.medicare.gov/hospicecompare

• Launched August 16, 2017

• Two ways to search for a hospice– Hospice agency name

– Location (zip code or city, state, or state)

• HIS data– 12 months of data

– Minimum of 20 stays

– Updated quarterly

More measures coming in 2018

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Hospice Compare


Hospice Compare Data

• Patient Preferences– Treatment Preferences (#1641)

– Beliefs/Values (#1647)

• Managing pain and treating symptoms– Pain Screening (#1634)

– Pain Assessment (#1637)

– Dyspnea Screening (#1639)

– Dyspnea Treatment (#1638)

– Opioid/Bowel Management (#1617)

• Data is available to download

– General Info*

– National

– Provider

– Hospice CAHPS national averages

* Know issue with incorrect demographic data

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Comparisons: Table Layout

No state comparisons or star ratings


Comparisons: Graph Layout

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Ongoing Review of All Available HQRP Data

• Hospice Compare • HIS‐based Measures

– National averages– CASPER reports

• Hospice‐Level Quality Measure Report• Hospice Patient Stay‐Level Quality Measure Report

– Vendor or EMR reports *– Internal reports and comparisons

• Hospice CAHPS‐based Measures– National averages– Survey‐vendor reports *– Internal reports and comparisons

Critical for In‐depth Analysis

‐ Drill down to identify key drivers of performance

‐ HIS results by admissionto tie back to operations

‐ Component measure scores in addition to composite scores

* Not official results - only CMS published results are official.


Quality Measure Reports on CASPER:Hospice‐Level Quality Measure Report

• Results by CCN

• 7 HIS quality measures– Numerator/denominator

– CCN‐level score

– National average

– Percentile rank

• On demand timeframe

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Quality Measure Reports on CASPER:Patient Stay‐Level Quality Measure Report

• Drilldown report

• Results by CCN

• Includes Type 1 as well as Type 2 and 3 stays


Vendor Reports

• Reminder: Vendor scores will differ slightly from risk adjusted CMS scores

• Comparative national benchmarks

• Integrated HQRP Report combines both HIS and Hospice CAHPS quality measures

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Vendor Reports

• Reports to help identify what is driving performance:– HIS scores by admission date for

performance improvement

– Additional details from HIS record beyond the Quality Measure scores

– Patient‐level drilldown from report


Internal & External Comparisons

• External– National comparative

benchmarks – Data captured and

reported in the same way– Understand if data is risk

adjusted or not

• Internal– Compare scores by

region/location/team – Identify opportunities for

improvement– Celebrated (and learn from)

internal champions

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Visits in Final Week

• CMS: On any given day during the last 7 days of a hospice election, nearly 44% of the time the patient has not received a skilled visit (skilled nursing or social work visit). Based on FY2016 claims data (10/1/15 – 9/30/16)

Visit Measure 2 - Percent of patients who died with a LOS > 1 day who received at least 2 visits by a Medical Social Worker, Chaplain, LPN or Hospice Aide in the last 7 days of life.Excludes patient stays missing either admission date or discharge date, patients who received continuous home care, respite care or general inpatient care in the last 7 days of life, and patients with a LOS of 1 day.

84.9%

VISIT MEASURE 2Numerator - From those in the denominator, the number who received at least 2 visits by a Medical Social Worker, Chaplain, LPN or Hospice Aide in the last 7 days of life.

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Denominator - Patients who died with a LOS > 1 day with Type 1 stays who did not receive continuous home care, respite care or GIP care in the last 7 days of life.Excludes patient stays missing either admission date or discharge date, patients who received continuous home care, respite care or general inpatient care in the last 7 days of life, and patients with a LOS of 1 day.

166

Denominator - Patients who died with Type 1 stays who did not receive continuous home care, respite care or GIP care in the last 3 days of life.Excludes patient stays missing either admission date or discharge date, and patients who received continuous home care, respite care or general inpatient care in the last 3 days of life.

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Visit Measure 1 - Percent of patients who died who received at least 1 visit by a Registered Nurse, Physician, Registered Nurse Practitioner or Physician Assistant in the last 3 days of life.Excludes patient stays missing either admission date or discharge date, and patients who received continuous home care, respite care or general inpatient care in the last 3 days of life.

87.8%

Visit Measure 1 - National 86.7%

VISIT MEASURE 1Numerator - From those in the denominator, the number who received at least 1 visit by a Registered Nurse, Physician, Registered Nurse Practitioner or Physician Assistant in the last 3 days of life.

151

Visit Measure 2 - Percent of patients who died with a LOS > 1 day who received at least 2 visits by a Medical Social Worker, Chaplain, LPN or Hospice Aide in the last 7 days of life.Excludes patient stays missing either admission date or discharge date, patients who received continuous home care, respite care or general inpatient care in the last 7 days of life, and patients with a LOS of 1 day.

84.9%

VISIT MEASURE 2Numerator - From those in the denominator, the number who received at least 2 visits by a Medical Social Worker, Chaplain, LPN or Hospice Aide in the last 7 days of life.

141

Denominator - Patients who died with a LOS > 1 day with Type 1 stays who did not receive continuous home care, respite care or GIP care in the last 7 days of life.Excludes patient stays missing either admission date or discharge date, patients who received continuous home care, respite care or general inpatient care in the last 7 days of life, and patients with a LOS of 1 day.

166

Denominator - Patients who died with Type 1 stays who did not receive continuous home care, respite care or GIP care in the last 3 days of life.Excludes patient stays missing either admission date or discharge date, and patients who received continuous home care, respite care or general inpatient care in the last 3 days of life.

172

Visit Measure 1 - Percent of patients who died who received at least 1 visit by a Registered Nurse, Physician, Registered Nurse Practitioner or Physician Assistant in the last 3 days of life.Excludes patient stays missing either admission date or discharge date, and patients who received continuous home care, respite care or general inpatient care in the last 3 days of life.

87.8%

Visit Measure 1 - National 86.7%

VISIT MEASURE 1Numerator - From those in the denominator, the number who received at least 1 visit by a Registered Nurse, Physician, Registered Nurse Practitioner or Physician Assistant in the last 3 days of life.

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Hospice Compare Timeline

• Launch: August 16, 2017– 7 HIS quality measures– Rolling 12‐month timeframe– Minimum of 20 patient stays

• Winter 2018– 8 Hospice CAHPS measures– Rolling 8‐quarter timeframe– Minimum of 30 completed surveys

• Future– Star Ratings– Additional quality measures

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Important Reminders /

Upcoming Changes and Mandates


Annual ICD‐10 Diagnosis Update

• Annual ICD‐10 diagnosis update will occur on October 1, 2017

• Software vendors normally update their systems prior to October 1 to allow for proper selection of codes for documentation and billing purposes

• Hospice providers should prepare to train staff on new codes/revised codes to ensure proper usage once new codes are released.

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Emergency Preparedness

• By November 15, 2017

– Activation of Emergency Preparedness Program

• Policies and Procedures developed

• Staff training completed

• Program testing (completed)

• Evidence of community collaboration


Reminder: Sequestration Still in Effect

• The 2011 Budget Control Act mandates cuts equally over nine years (2013 – 2021).

• Does not apply to Medicaid.

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Social Security Number Removal Initiative (SSNRI)

• The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015) requires CMS to remove Social Security Numbers from all Medicare cards by April 2019.

• A new Medicare Beneficiary Identifier (MBI) will replace the SSN‐based Health Insurance Claim Number (HICN) on the new Medicare cards for Medicare transactions like billing, eligibility status, and claim FISS/DDE

• New cards will be mailed beginning in April of 2018

• Transition period will begin no earlier than April 1 of 2018 and run through December 31, 2019.

https://www.cms.gov/medicare/ssnri/index.html


• During the transition period, providers will be able to use either the SSN or the MBI to exchange data with CMS.

• The MBI will be: – Clearly different than the HICN and RRB number

– Be 11‐characters in length

– Be made up only of numbers and uppercase letters (no special characters)

– Be randomly generated. (The characters are "non‐intelligent," which means they don't have any hidden or special meaning.)

Social Security Number Removal Initiative (SSNRI)

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Hospice Item Set Threshold Reminder

• Hospice Item Set Timeliness Compliance Threshold finalized in the FY2016 Final Rule is still in effect. (Not complying = 2% payment reduction!)– Jan 1st – Dec 31st 2017: 80% of all HIS records must be submitted

within the 30 day timeframe

– Jan 1st 2018 and beyond: 90% of all HIS records must be submitted within the 30 day timeframe

• CASPER Report:Hospice Timeliness Compliance Threshold Report

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Monitor your MAC Claims Processing Site

http://www.palmettogba.com/Palmetto/Providers.nsf/docsCat/JM%20Part%20A~Articles~Claims%20Processing%20Issues%20Log?open&Expand=1http://www.cgsmedicare.com/hhh/claims/FISS_Claims_Processing_Issues.htmlhttp://www.ngsmedicare.com

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Stay in the Loop


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The HEALTHCAREfirst Difference

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• Over 25 years of experience dedicated to home health and hospice agencies

• Largest suite of comprehensive EHR software, revenue cycle management services, and advanced analytics

• Compe ve and affordable, monthly fee with no hardware to buy or long‐term contracts

• Strong reputation for exceptional service and support


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